S. 44B : Shipping business-Non-residents-Computation-GST-Section 44B overrides the provisions of S. 29-Section 145A is not applicable for computing deemed income-GST not to be included Book profit-Income offered income under deeming provision-Provsion of book profit is not applicable-DTAA-India Hing Kong. [S. 29,90, 115JB, 145A, Art.8]

S.37(1): Business expenditure-Contributions to the Investors Service Fund is mandatory-Club membership fees of directors-Allowable as business expenditure.

S.37(1): Business expenditure-Corporate Social Responsibility expenditure-Allowable as deduction. [37(2) Explanation.]

S. 36(1)(iii) :Interest on borrowed capital-Interest-free advances given to farmers-Commmercial expediency-Allowable as deduction.

S.37(1): Business expenditure-Seizure of Truck-Penalty, fine, etc.-Levy of penalty under State VAT law-Issue pending before Commr. of Commercial Taxes-Not allowable as deduction-Liberty is given to the assessee to file application under s. 154 in case the issue pending before the first appellate authority is decided in favour of the assessee or it is adjudicated as compensation or compounding.[S. 37(1), Explantion 1, 154]

S.14A : Disallowance of expenditure-Exempt income-salaries paid to the employees of the treasury department-Allocaation of eexpenses on the basis of area occupied by the department-Held to be reasonable-Book profit-Adjustment of disallowance under s. 14A is not required to be made in the book profit for MAT liability. [S.115JB, R.8D]

S. 12AB: Procedure for fresh registration-Religious trust-Trust for the benefit of particular community-Jain community and to propagate Jainism-Order rejecting the application is affirmed. [S. 11, 12, 12AB(4) 13(1)(b)]

S. 11 : Property held for charitable purposes-Revised claim by rectification application-Filed within the time prescribed u/s 139(5)-No intimation was issued u/s 143(1)-Denial of exemption is not valid.[S. 139(5) 143(1), 154(8)]

S. 10 (23C): Educational institution-Wrong sub section is mentioned in the return-Mistake of counsel-Exemption is allowed-Non foling of audit report-Not applicable to university-Entitle to eexxemption-Delay of 691 aand 706 days-Mistake of counsel-Delay is condoned. [S. 10(23C)(iiiab), 12A, 44AB,253(5), 254(1)

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Not dependent agent-No substantial transaction-Income is not chargeable to tax in India-Fees for technical services-Reimbursement of salaries of seconded employees-Tax deducted at source-issue is remitted to the AO for fresh adjudication as per law-DTAA-India-USA.[S.90, Art, 12(4)]